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EPA, OSHA and DOT Training Requirements and Regulations

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EPA, OSHA and DOT Training Requirements and Regulations

EPA, OSHA and DOT Training Requirements and Regulations

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Documented employee training is required by federal laws (under EPA, OSHA and DOT) in the following situations. Penalties can be quite substantial for employers who fail to provide qualified, documented training:


Federal regulation: 49 CFR 172.702

(a) A hazmat employer shall ensure that each of its hazmat employees is trained in accordance with the requirements prescribed in this subpart.

(b) Except as provided in Sec. 172.704(c)(1), a hazmat employee who performs any function subject to the requirements of this subchapter may not perform that function unless instructed in the requirements of this subchapter that apply to that function. It is the duty of each hazmat employer to comply with the applicable requirements of this subchapter and to thoroughly instruct each hazmat employee in relation thereto.

(d) A hazmat employer shall ensure that each of its hazmat employees is tested by appropriate means on the training subjects covered in Sec. 172.704.

If you doubt the seriousness, click here to go to the U.S. DOT web page on this subject! (afterwards, click your "Back" key to return here)

OSHA 40 hr (also called HazWoper)

Federal regulation: 29 CFR 1910.120

Required for employees who work at:

Hazardous waste facilities 40 CFR Part 264/265 hazardous waste storage, treatment or disposal operations.

Cleanup operations required by a governmental body, whether federal, state, local, or other - involving hazardous substances that are conducted at uncontrolled hazardous waste sites (including but not limited to, the EPA's National Priority List (NPL), state priority site lists, sites recommended for the NPL and initial investigation of government identified sites before the presence of absence of hazardous substances has be ascertained).

Corrective actions involving cleanup operations at sites covered by RCRA.

Voluntary cleanup operations at sites recognized by Federal, state, local, or other governmental bodies as uncontrolled waste sites.

For more information, provided by OSHA:
Click here for an interpretation memo with a question and answer section.
Click here for the compliance directive .

OSHA HazComm

Hazards Communications Regulations

Federal Regulation: 29 CFR 1910.1200

This is commonly know as the regulations that requires employers to maintain an MSDS (Material Safety Data Sheet) system and hazard training for employees.

1910.1200(a)(1): "The purpose of this section is to ensure that the hazards of all chemicals produced or imported are evaluated, and that information concerning their hazards is transmitted to employers and employees. This transmittal of information is to be accomplished by means of comprehensive hazard communication programs, which are to include container labeling and other forms of warning, material safety data sheets and employee training."

Click here to see the OSHA Compliance Directive for this rule on the OSHA web site.

OSHA Safety Requirements

Respiratory protection, Hearing Conservation, PPE, etc.

Federal Regulation: Many, such as this example, 29 CFR 1910.1234

1910.134(a)(2) * Respirators shall be provided by the employer when such equipment is necessary to protect the health of the employee. The employer shall provide the respirators which are applicable and suitable for the purpose intended. The employer shall be responsible for the establishment and maintenance of a respiratory protection program which shall include the requirements outlined in paragraph (c) of this section.

1910.134(c)(1)(vii) * Training of employees in the respiratory hazards to which they are potentially exposed during routine and emergency situations;